P03 LSJ_LGY Extension_Redacted.pdf

LGY Legacy Suite Applications Control Number: VA-25-00071368

LIMITED-SOURCES JUSTIFICATION

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition and Logistics Technology Acquisition Center (TAC) 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: The proposed sole source modification is for a continuation of General Services Administration (GSA) Multiple Award Schedule (MAS) Contract GS-35F- 540GA Task Order (TO) 36C10B20F0172 with Accenture Federal Services, LLC (AFS), 800 N Glebe Rd Suite 300, Arlington, VA 22203. This modification will be a four (4) month extension of specific sections of the current task order to continue the operational maintenance and sustainment of the Veterans Benefits Administration (VBA), Loan Guaranty (LGY), and legacy suite of applications while the new requirement is competitively solicitated.

3. Description of the Supplies or Services: The Office of Information and Technology (OIT) and VBA LGY Business Leadership require continued operational maintenance and sustainment support of the VBA LGY legacy suite of applications. The VBA LGY legacy applications are currently the only suite of tools available to the VBA LGY Product Line for managing and administering the VBA Home Loan Program. This action is required to ensure continuous operation, administration, maintenance and sustainment of the VBA Home Loan Program benefit for Veterans and their dependents.

TO 36C10B20F0172 was competitively awarded to AFS on June 16, 2020. A logical follow-on modification was awarded on June 27, 2024, and ends on June 26, 2025. For this reason, a modification to the existing task order for a four-month extension is needed with the current vendor to continue the operational sustainment of the LGY legacy applications until the new contract/task order can be awarded. The goal of the four-month extension is to maintain the present systems and applications to ensure they can support and execute all present functionality to allow VA to continue providing home loan guarantees to our Nation’s Veterans. This four-month task order extension will leverage the following critical CLINs that are needed to keep the operational demands working:

Project Management (CLIN 1) 2 System Team (CLIN 2) Help Desk, Operations and Security, RHEL8 Upgrade (T&M) (CLIN 3) 5 System Teams (CLIN 5) 14 Feature Teams (CLIN 7)

These CLINs provide services in the following areas: Operations and Security, Legacy Sustainment, Veterans Health Benefit (VHB) Sustainment for Specially Adapted Housing (SAH) and Special Housing Adaptation (SHA) Grants, Help Desk – Tier 1 Customer Care Support, Veteran Appeals Support Program (VASP) Decommission, RHEL8 Upgrade, and Salesforce Migration.

The total estimated value of the proposed 4-month extension is The TO value will increase from to

Statutory Authority: This acquisition is conducted under the authority of the Multiple- Award Schedule Program. The specific authority providing for a limited source award is Federal Acquisition Regulation (FAR) Part 8.405-6(a)(1)(i)(B), “Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.”

Rationale Supporting Use of Authority Cited Above: The proposed source for this action is AFS, 800 N Glebe Rd Suite 300, Arlington, VA 22203. These requirements are needed to continue the operational sustainment of the LGY legacy applications that began with the previously competitively awarded TO to AFS. The work involves managing and administering the VBA Home Loan Program for Veterans. The existing task order that currently sustains, supports, and staffs the LGY program ends on June 2 , 2025. The requested action is necessary to ensure continuity of services for administration of the home benefits offered to Veterans until the new contract is awarded. LGY is currently using outdated software that uses 20-year-old technology which makes it difficult to quickly find resources that can meet LGY’s needs. AFS has the unique and specialized knowledge required to sustain the outdated software. Additionally, the present contractor has five years of understanding and knowledge of the environment, platform, and software versions to quickly address issues.

Operations and Security – VBA LGY Platforms require monthly security patching and maintenance for over 18 environments, 180 virtual machines, and 37 databases. It also requires production monitoring for 80+ batch jobs and incident response for 10+ severity level 1/2 incidents per month. Not having this support will make the VA vulnerable to system outages and potential security incidents.

Legacy Sustainment - Break-fix, Tier 2/3 Support, and Incident response for the Loan Production and Origination System (LGY/FFPS), VA Loan Electronic Reporting Interface (VALERI), and Program Analytics and Operational Reporting System (LGA). The support of these systems comprises four (4) unique production applications, over 130 Tier 2 help desk tickets per month with a mean time of approximately 8 days to resolve and approximately 3 Tier 3 (production bugs) tickets per month to resolve high and critical issues. Not having this support will negatively impact the VA Home Loan Program as there would not be any staff able to address system outages, break-fixes, incident response, and the needed Tiers 2 and 3 support.

VHB Sustainment (SAH/SHA) - Support for Special Adaptive Housing. The program is anticipating more than 150 Tier 2 tickets per month and over 25 Tier 3 (production bugs) tickets per month to resolve high and critical issues during the immediate period. Not having the needed production deployment application support will negatively impact the SAH/SHA as there will be nobody to address potential system or user issues and incident responses.

Help Desk - Tier 1 Customer Care Support – The LGY program anticipates approximately 1,600 tickets per month with a mean time of approximately 1 day to resolve. Not having the needed help desk support will leave internal and external VBA and LGY users without the urgent assistance needed, impacting Veterans vulnerable to not receiving the earned home loan benefit mandated by VA Credit & Home Loan Program Reform Acts.

Additionally, three tasks for completion must occur by the end of 2025 to be in compliance with recent and unforeseen Congressional mandates:1.) Dissolvement of the Veterans Affairs Servicing Purchase (VASP) Program; 2.) The recent end-of-life mandate to convert from Rules SalesForce Builder to SalesForce Workflow; and 3.) The Rhel8 migration from Rhel7.

VASP Decommission - VA Home Loan Program Reform Act (H.R.1815) is being proposed to help keep 40,000 Veterans in their homes since Congress is ending VASP. Without the development team available to support the reform act, there will be over 40,000 veterans vulnerable to losing their homes as these are delinquent loans and require some form of mitigation strategy. The LGY program must comply with both initiatives in a timely manner to avoid Veteran home loss.

Salesforce Migration for Utilization of VALERI - Components of the VALERI system supporting the Servicing of VA Loans will reach end of life in December of 2025. Migration to the SalesForce replacement function is needed to be in compliance with VA’s Technical Reference Model (TRM). The contract support from Salesforce and Digital Transformation Center’s allowance of future releases will not happen unless VALERI migrates to the new module.

RHEL8 Upgrade - End of Life (EOL) occurs when a software version is no longer going to be supported by the manufacturer. The end of life by the manufacturer and security vulnerabilities have created the need to update from Rhel7 to Rhel8. The process to migrate form Rhel7 is creating a lengthening of schedule thus causing LGY to have a need to upgrade. If the program cannot complete this migration, systems could be taken offline as Rhel9 is coming soon and the LGY program will be non-compliant with VA’s TRM. This is a major upgrade required to maintain operability and security of the systems. Additionally, this work requires experienced Continuous Integration/Continuous Delivery/Deployment, Amazon Web Service, and Network engineers who can perform the in-place upgrade without impacting LGY’s ability to operate.

Utilizing AFS is the only feasible method to meet the Government’s critical requirements and support Veterans. AFS is uniquely positioned to provide the 4 months of continued support, having supported VA in this capacity for the past five years. They are familiar with VA’s operating environment such as the VBA LGY Suite of applications, internal policies, and procedures. AFS’ continued work is crucial due to its unique, intimate, and specialized knowledge, understanding, and lessons learned over the past five years of support to VA.

AFS has over 5 years of specific knowledge of the Web LGY suite of applications that are not found in the commercial space as this is 20-year-old custom code. Also, only AFS has the requisite knowledge to perform the RHEL 7 to 8 and Resource builder update to Workflows in Salesforce. Additionally, AFS has all of the knowledge on the MuleSoft instance that operates the VALERI application. AFS has the technical and institutional knowledge, experience, and staff in place to prevent any undue delays. Not only do they have the highly specialized knowledge and technical skills required to maintain the outdated technology supporting the legacy suite of applications, this will also avoid cost from delays, disruption of services, and duplication of efforts.

Furthermore, the VA LGY Product line has been actively engaged in award administration of a follow-on task order with the Technology Acquisition Center since May of 2024. That package has reached solicitation but due to unforeseen changes in administration and impacts on contract procedures and processes surrounding oversight, the task order award has been significantly delayed until July 2025. The RFQ for the new award was issued on May 29, 2025, and the anticipated date for the new award is August 2025. Subsequently, there will be a transition period from August to October 2025. This risk and timeline for transition coupled with the critical nature of the RHEL upgrade, VALERI, and request to decommission VASP requires a 4-month extension for continued services in the specified technical function areas. During this transition, no further enhancements of the VBA LGY legacy suite of applications will occur along with any other environment within the LGY Product Line.

These critical initiatives support keeping Veterans in their homes through expedited loan servicing work and analytics efforts to identify cases where Veterans are wrongfully denied or misled on their eligibility determination for the Home Loan benefit. Going without the housing benefits offered to eligible Veterans and their beneficiaries would put Veterans at great risk, potentially slowing or inhibiting benefits from being offered. Lapse or disruption in support and continuity would cause degradation of these critical services, which would impact VA, Veterans, and their beneficiaries from obtaining and/or retaining their homes.

6. Efforts to Obtain Competition: Market research was conducted, the details of which are in Section 8 of this document. Although there are other vendors with appropriately skilled employees, none could prove they fully understood the complex dependencies and interfaces to complete this work without a duplication of time and effort to provide a smooth transition. In accordance with FAR 5.301 and 8.405-6(a)(2), this action will be synopsized at award on the Contracting Opportunities Page and the justification will be made publicly available.

7. Actions to Increase Competition: No barriers to future competition are anticipated. The Government plans to award a new contract in August 2025. The VA TAC issued a competitive solicitation for the new contract on May 29, 2025. This extension will provide continued operational sustainment support for an additional 4-months up until the new contract is awarded.

8. Market Research: VA’s technical experts conducted market research for the requested four month extension in May 2025 to ascertain if other vendors could satisfy the requirements via Request for Information and posting of the Performance Work Statement, which included technical functional areas for the same scope of work; Sustainment and Operational Maintenance, Security, Help desk, VASP and EOL. While responses were received and alternative sources were found that could meet VA’s general capabilities, none of the contractors demonstrated the ability to onboard, commence, and accomplish these services beginning on June 27, 2025, through the anticipated award and transition to a new task order.

While market research indicates there are several contractors in the federal marketplace that are interested in performing the required services, only the incumbent possesses a full understanding of the scope of work, the requisite institutional knowledge, and the staff in place that would allow for seamless continuation of these critical initiatives. Any other vendor would need to be onboarded, trained, and brought up to speed on the VA operating environment. Further, only AFS is uniquely positioned to provide 4 months of continued support since they have institutional knowledge of VA’s operating environment such as the VBA LGY Suite of applications, internal policies, and procedures. Using any other vendor would not only cause delays in transitioning but also create risk in lapse of service in addition to duplication of time and costs as outlined in Section 5 of this justification.

VA cannot experience a gap in support as these services are necessary to process Home Loans for Veterans required by VA. Therefore, only AFS is capable of providing the services required at the level of quality required because only AFS is in a unique or highly specialized position to perform the work as required.

9. Other Facts: N/A

13. Office of General Counsel (OGC) Review: I have reviewed this document and find it legally sufficient, based on the representations set forth in the documents and, if any, attachments. The Competition Advocate’s approval is an independently supported decision not wholly reliant on the legal sufficiency determination.

Date

Office of General Counsel

Approval

In my role as Advocate for Competition, based on the foregoing justification, I hereby approve the acquisition of the four-month extension of the current task order for operational maintenance and sustainment of the VBA, LGY and legacy suite of applications, on an other than fair opportunity basis pursuant to the statutory authority cited in Section 4 above, subject to availability of funds, and provided that the property and services herein described have otherwise been authorized for acquisition.

Date

Advocate for Competition Technology Acquisition Center Procurement, Acquisition, and Logistics Department of Veteran Affairs

6/3/25